Return-to-Work Policy

To promote employee health and recovery through early intervention and timely return-to-work opportunities for occupational and non-occupational injuries and illnesses.

This policy applies to Seneca employees and return-to-work service providers.

Change or adjustment to job duties or work environments that removes barriers for individuals with disabilities to perform the essential duties of their position in a manner that is healthy and safe.

Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, congenital disability or illness.

Physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device; a condition of mental impairment or a developmental disability.

A learning disability or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.

A mental disorder, or an injury or disability for which benefits were claimed or received through an insurance plan established under the Workplace Safety and Insurance Act, 1997.

A member of one of the following colleges:

• College of Audiologists and Speech-Language Pathologists of Ontario
• College of Chiropractors of Ontario
• College of Nurses of Ontario
• College of Occupational Therapists of Ontario
• College of Optometrists of Ontario
• College of Physicians and Surgeons of Ontario
• College of Physiotherapists of Ontario
• College of Psychologists of Ontario
• College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario

The process by which an employee resumes work following a period of absence due to a resulting from an occupational or non-occupational injury or illness.

A third party contracted to medically adjudicate claims, manage workplace absences and support employees safe return to work after an absence.

The point at which it is determined that providing an employee with an accommodation would result in excessive impact on the business or operations of Seneca based on financial costs, outside sources of funding, or health and safety risks.

1. Seneca is committed to:
   • maintaining a safe, healthy and supportive workplace
   • providing early intervention and support to employees who are unable to work due to a disability
   • following a fair and consistent approach to establishing a safe and timely return to work in accordance with applicable legislation
   • ensuring accommodations for employees who have medical restrictions or limitations with respect to their return to work in accordance with applicable policies, legislation and collective agreements, to the point of undue hardship

1. Human Resources is responsible for:
   • addressing employee and supervisor questions throughout the return-to-work process
   • assisting in the development and facilitation of return-to-work plans
   • coordinating with the return-to-work service provider to understand the medical restrictions and limitations to support return-to-work plans within the limits of undue hardship
   • facilitating return-to-work meetings with affected employees, their supervisors and, where applicable, union representatives
   • providing employees with guidelines for short-term disability leave and medically necessary accommodations
   • making new employees aware of this policy and related materials
   • maintaining and safeguarding employees’ confidential information
2. Supervisors are responsible for:
   • ensuring employees are informed about the administrative processes related to leaves and the resources available 
   • maintaining contact with absent employees during the return-to-work process
   • assisting in the development and facilitation of return-to-work plans
   • identifying return-to-work assignments and accommodations, as required, in consultation with Human Resources, based on the supported medical restrictions and limitations 
   • participating in return-to-work meetings
   • implementing return-to-work arrangements for employees in accordance with the return-to-work plan and applicable policies and legislation 
   • monitoring and evaluating return-to-work plans
   • maintaining and safeguarding employees’ confidential information
3. Employees are responsible for:
   • informing Seneca of their medical absence or accommodation needs related to a disability
   • cooperating with the return-to-work service provider to provide required documentation related to medical leaves and accommodations
   • participating in good faith in the assessment and implementation of return-to-work activities and accommodations
   • actively participating in rehabilitative treatment as needed
   • collaborating with supervisors, Human Resources and the return-to-work service provider to determine an appropriate return-to-work plan based on their restrictions and limitations
4. Union representatives are responsible for:
   • representing and supporting employees in the return-to-work process
   • educating employees on their rights and responsibilities regarding their return to work in accordance with applicable legislation, policies and collective agreements
   • working with Seneca and employees to identify, support and implement return-to-work plans
5. Return-to-work service providers are responsible for:
   • assisting in the development and facilitating of return-to-work plans
   • acting as the primary point of contact for employees throughout their absences and return to work
   • requesting necessary documentation to support decisions relating to disabilities requiring an absence or accommodation
   • relying on healthcare provider documentation to determine employees’ benefit eligibility and to assess restrictions and/or limitations
   • ensuring employees are made aware of when and how information is shared throughout the return-to-work process including their rights and responsibilities regarding confidentiality
   • maintaining and safeguarding employees’ personal health information in accordance with applicable legislation
   • receiving and assessing appeals when a disability or accommodation claim is not medically supported

1. The return-to-work process comes into effect when an employee has been absent for 10 days due to an injury or illness.
2. Employees will return to work only when they are medically cleared to do so.
3. Medically supported, reasonable accommodations will be provided for employees with temporary or permanent medical restrictions and/or limitations in accordance with applicable policies, legislation and collective agreements.
4. Return-to-work service providers may request additional information if the information provided by a healthcare provider is insufficient for understanding an employee’s restrictions/limitations and/or fitness to return to work.
5. A return-to-work plan will be developed based on available options to determine the best course of action considering factors such as:
   • operational needs
   • essential duties of the employee’s job
   • the expected length of the required accommodation(s)
   • the type of modified or suitable alternate work that may be required
6. Review of a return-to-work plan will be required when:
   • the employee’s work location or duties change 
   • the nature or impact of the employee’s injury/illness/disability changes
   • the employee or Seneca has reason to believe that an accommodation is no longer appropriate or required

1. Employees may appeal accommodation denials through the return-to-work service provider.
2. If resolution is not achieved through the return-to-work service provider’s appeal process, a unionized employee may follow the dispute resolution procedures outlined in the relevant collective agreement.
3. Where an employee refuses to provide necessary medical documentation or return to work when medically cleared, payment of salary/benefits may be suspended, terminated and/or the employee may face discipline up to and including termination.
4. In the event the medical documentation is deemed insufficient by the return-to-work service provider, or the dispute resolution is unsuccessful, Seneca may suspend or deny payment of short-term disability benefits until such medical documentation is provided.

• Accessibility for Ontarians with Disabilities Act
• Freedom of Information and Protection of Privacy Act, 1990
• Occupational Health and Safety Act, 1990
• Ontario Human Rights Code, 1990
• Personal Health Information Protection Act, 2004
• Workplace Safety and Insurance Act, 1997

• Accessibility Policy
• Occupational Health and Safety Policy
• Respectful Workplace Policy

• None

Approval Date: June 2023

Last Revision: June 2026